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LCD L39849: Opioid Treatment Programs

LCD L39849, Opioid Treatment Programs, is the Local Coverage Determination that Palmetto GBA applies to claims from 7 states (AL, GA, NC, SC, TN, VA, WV), effective 2024-10-20. The policy text runs 472 words, and its billing and coding article A59718 lists 39 ICD-10-CM codes that support medical necessity for 20 procedure codes. No other contractor publishes a policy with this title.

QuickIntell editorial content · Legacy registry date · Review not verified

Data effective
Data currency: Medicare Coverage Database LCD export release of September 24, 2026 (effective September 20, 2026). Next CMS release: weekly (Thursdays) for the MCD.
Contractor
Palmetto GBA
States and territories
7
AL GA NC SC TN VA WV
Revision effective
2024-10-20
Original effective
2024-10-20
Policy text
472 words
Covered ICD-10 codes (articles)
39

Where this LCD applies

Each contract number is a jurisdiction on the remittance; the policy binds claims processed under these contracts and no others.

Contracts that apply LCD L39849
ContractContractorTypeStates
11201Palmetto GBAA and B and HHH MACSC
11301Palmetto GBAA and B and HHH MACVA
11401Palmetto GBAA and B and HHH MACWV
11501Palmetto GBAA and B and HHH MACNC
11202Palmetto GBAA and B and HHH MACSC
11302Palmetto GBAA and B and HHH MACVA
11402Palmetto GBAA and B and HHH MACWV
11502Palmetto GBAA and B and HHH MACNC
10111Palmetto GBAA and B MACAL
10211Palmetto GBAA and B MACGA
10311Palmetto GBAA and B MACTN
10112Palmetto GBAA and B MACAL
10212Palmetto GBAA and B MACGA
10312Palmetto GBAA and B MACTN

Billing and coding: diagnoses and procedure codes

Since 2019 the codes live in the companion article rather than the LCD. Billing and Coding A59718 (Billing and Coding: Opioid Treatment Programs) carries the diagnosis and procedure lists the contractor loads as the claims edit. CPT codes are shown as bare numbers because the descriptors are licensed by the AMA; HCPCS Level II descriptors are public and shown.

A59718: Billing and Coding: Opioid Treatment Programs (Billing and Coding, effective 2026-01-01)

Covered ICD-10-CM codes
39
1 group
Non-covered ICD-10-CM codes
299
Procedure codes listed
20
Full article
cms.gov record
First 24 covered ICD-10-CM codes in A59718
ICD-10-CMDescription (FY2027)
F11.10—
F11.11—
F11.120—
F11.121—
F11.122—
F11.13—
F11.14—
F11.150—
F11.151—
F11.181—
F11.182—
F11.188—
F11.19—
F11.20—
F11.21—
F11.220—
F11.221—
F11.222—
F11.23—
F11.24—
F11.250—
F11.251—
F11.281—
F11.282—

Procedure codes: G0137 (Intensive Outpatient Services; Weekly Bundle, Minimum Of 9 Services Over A 7 Contiguous Day Period, Which Can Include Individual And Group Therapy With Physicians Or Psychologists (Or Other Mental Health Professionals To The Extent Authorized Under State Law); Occupational Therapy Requiring The Skills Of A Qualified Occupational Therapist; Services Of Social Workers, Trained Psychiatric Nurses, And Other Staff Trained To Work With Psychiatric Patients; Individualized Activity Therapies That Are Not Primarily Recreational Or Diversionary; Family Counseling (The Primary Purpose Of Which Is Treatment Of The Individual'S Condition); Patient Training And Education (To The Extent That Training And Educational Activities Are Closely And Clearly Related To Individual'S Care And Treatment); Diagnostic Services; And Such Other Items And Services (Excluding Meals And Transportation) That Are Reasonable And Necessary For The Diagnosis Or Active Treatment Of The Individual'S Condition, Reasonably Expected To Improve Or Maintain The Individual'S Condition And Functional Level And To Prevent Relapse Or Hospitalization, And Furnished Pursuant To Such Guidelines Relating To Frequency And Duration Of Services In Accordance With A Physician Certification And Plan Of Treatment (Provision Of The Services By A Medicare-Enrolled Opioid Treatment Program); List Separately In Addition To Code For Primary Procedure), G0532 (Take-Home Supply Of Nasal Nalmefene Hydrochloride; One Carton Of Two, 2.7 Mg Per 0.1 Ml Nasal Sprays (Provision Of The Services By A Medicare-Enrolled Opioid Treatment Program);( List Separately In Addition To Each Primary Code)), G0533 (Medication Assisted Treatment, Buprenorphine (Injectable) Administered On A Weekly Basis; Weekly Bundle Including Dispensing And/Or Administration, Substance Use Counseling, Individual And Group Therapy, And Toxicology Testing If Performed (Provision Of The Services By A Medicare-Enrolled Opioid Treatment Program)), G0534 (Coordinated Care And/Or Referral Services, Such As To Adequate And Accessible Community Resources To Address Unmet Health-Related Social Needs, Including Harm Reduction Interventions And Recovery Support Services A Patient Needs And Wishes To Pursue, Which Significantly Limit The Ability To Diagnose Or Treat An Opioid Use Disorder; Each Additional 30 Minutes Of Services (Provision Of The Services By A Medicare-Enrolled Opioid Treatment Program); (List Separately In Addition To Each Primary Code)), G0535 (Patient Navigational Services, Provided Directly Or By Referral; Including Helping The Patient To Navigate Health Systems And Identify Care Providers And Supportive Services, To Build Patient Self-Advocacy And Communication Skills With Care Providers, And To Promote Patient-Driven Action Plans And Goals; Each Additional 30 Minutes Of Services (Provision Of The Services By A Medicare-Enrolled Opioid Treatment Program); (List Separately In Addition To Each Primary Code)), G0536 (Peer Recovery Support Services, Provided Directly Or By Referral; Including Leveraging Knowledge Of The Condition Or Lived Experience To Provide Support, Mentorship, Or Inspiration To Meet Oud Treatment And Recovery Goals; Conducting A Person-Centered Interview To Understand The Patient'S Life Story, Strengths, Needs, Goals, Preferences, And Desired Outcomes; Developing And Proposing Strategies To Help Meet Person-Centered Treatment Goals; Assisting The Patient In Locating Or Navigating Recovery Support Services; Each Additional 30 Minutes Of Services (Provision Of The Services By A Medicare-Enrolled Opioid Treatment Program); (List Separately In Addition To Each Primary Code)), G1028 (Take-Home Supply Of Nasal Naloxone; 2-Pack Of 8Mg Per 0.1 Ml Nasal Spray (Provision Of The Services By A Medicare-Enrolled Opioid Treatment Program); List Separately In Addition To Code For Primary Procedure), G2067 (Medication Assisted Treatment, Methadone; Weekly Bundle Including Dispensing And/Or Administration, Substance Use Counseling, Individual And Group Therapy, And Toxicology Testing, If Performed (Provision Of The Services By A Medicare-Enrolled Opioid Treatment Program)), G2068 (Medication Assisted Treatment, Buprenorphine (Oral); Weekly Bundle Including Dispensing And/Or Administration, Substance Use Counseling, Individual And Group Therapy, And Toxicology Testing If Performed (Provision Of The Services By A Medicare-Enrolled Opioid Treatment Program)), G2069 (Medication Assisted Treatment, Buprenorphine (Injectable) Administered On A Monthly Basis; Bundle Including Dispensing And/Or Administration, Substance Use Counseling, Individual And Group Therapy, And Toxicology Testing If Performed (Provision Of The Services By A Medicare-Enrolled Opioid Treatment Program)), G2073 (Medication Assisted Treatment, Naltrexone; Weekly Bundle Including Dispensing And/Or Administration, Substance Use Counseling, Individual And Group Therapy, And Toxicology Testing If Performed (Provision Of The Services By A Medicare-Enrolled Opioid Treatment Program)), G2074 (Medication Assisted Treatment, Weekly Bundle Not Including The Drug, Including Substance Use Counseling, Individual And Group Therapy, And Toxicology Testing If Performed (Provision Of The Services By A Medicare-Enrolled Opioid Treatment Program)), G2075 (Medication Assisted Treatment, Medication Not Otherwise Specified; Weekly Bundle Including Dispensing And/Or Administration, Substance Use Counseling, Individual And Group Therapy, And Toxicology Testing, If Performed (Provision Of The Services By A Medicare-Enrolled Opioid Treatment Program)), G2076 (Intake Activities, Including Initial Medical Examination That Is Conducted By An Appropriately Licensed Practitioner And Preparation Of A Care Plan, Which May Be Informed By Administration Of A Standardized, Evidence-Based Assessment, And That Includes The Patient'S Goals And Mutually Agreed-Upon Actions For The Patient To Meet Those Goals, Including Harm Reduction Interventions; The Patient'S Needs And Goals In The Areas Of Education, Vocational Training, And Employment; And The Medical And Psychiatric, Psychosocial, Economic, Legal, Housing, Physical Activity And/Or Nutrition Needs And Other Recovery Support Services That A Patient Needs And Wishes To Pursue, Conducted By An Appropriately Licensed/Credentialed Personnel (Provision Of The Services By A Medicare-Enrolled Opioid Treatment Program); List Separately In Addition To Each Primary Code), G2077 (Periodic Assessment; Assessing Periodically By An Otp Practitioner And Includes A Review Of Moud Dosing, Treatment Response, Other Substance Use Disorder Treatment Needs, Responses And Patient-Identified Goals, And Other Relevant Physical, Nutrition And Psychiatric Treatment Needs And Goals; May Be Informed By Administration Of A Standardized, Evidence-Based Assessment, Or The Need And Interest For Harm Reduction Interventions And Recovery Support Services (Provision Of The Services By A Medicare-Enrolled Opioid Treatment Program); List Separately In Addition To Each Primary Code), G2078 (Take-Home Supply Of Methadone; Up To 7 Additional Day Supply (Provision Of The Services By A Medicare-Enrolled Opioid Treatment Program); List Separately In Addition To Code For Primary Procedure), G2079 (Take-Home Supply Of Buprenorphine (Oral); Up To 7 Additional Day Supply (Provision Of The Services By A Medicare-Enrolled Opioid Treatment Program); List Separately In Addition To Code For Primary Procedure), G2080 (Each Additional 30 Minutes Of Counseling In A Week Of Medication Assisted Treatment, (Provision Of The Services By A Medicare-Enrolled Opioid Treatment Program); List Separately In Addition To Code For Primary Procedure), G2215 (Take-Home Supply Of Nasal Naloxone; 2-Pack Of 4Mg Per 0.1 Ml Nasal Spray (Provision Of The Services By A Medicare-Enrolled Opioid Treatment Program); List Separately In Addition To Code For Primary Procedure), G2216 (Take-Home Supply Of Injectable Naloxone (Provision Of The Services By A Medicare-Enrolled Opioid Treatment Program); List Separately In Addition To Code For Primary Procedure).

Coverage indications, limitations and medical necessity

OTP treatment is considered reasonable and necessary for beneficiaries meeting all of the following requirements:

• diagnosed with OUD using the Diagnostic and Statistical Manual for Mental Disorders, AND

• voluntarily chooses maintenance treatment, AND

• is currently addicted to an opioid drug

Initial assessment:

Upon admission to the OTP and before initiating pharmacotherapy, the beneficiary must undergo an initial assessment as part of the intake activities that complies with 42 CFR 8.12 (f)(2) and (4). To qualify as an initial assessment the following must be addressed and included in the documentation:

• Confirmation of the OUD diagnosis

• Complete medical history inclusive of concomitant medical conditions, psychiatric disorders, trauma, infectious disease, and pregnancy

• Physical exam (unless assessment is performed via telehealth)

• Mental health screening for psychiatric disorders

• Laboratory testing to include complete blood count, liver enzyme testing, tuberculosis screening, hepatitis B + C, and HIV. If laboratory testing is not performed, documentation of recent testing or the rationale for not testing must be included.

• Authenticated informed consent inclusive of treatment options discussed, risk/benefit consideration of pharmacotherapy, and the patient’s preferences for therapy.

• Formation of treatment plan with discussion of psychosocial treatment, support, and patient’s preference for these services.

• Assessment of withdrawal potential and the associated plan.

• Assessment of safety including overdose potential, prevention education, and offer of take-home naloxone.

Drug Testing:

Testing for drugs of abuse must be provided in accordance with 42 CFR 8.12(f)(6).

The use of other addictive drugs of abuse should not be a reason to withhold or suspend OUD treatment. However, those who are actively using substances during OTP are likely to require greater support including a more intensive level of care.

Periodic assessments are required in accordance with 42 CFR 8.12(f)(4). Periodic assessments must include documentation of the following:

• Evaluation of treatment progress and appropriate adjustments in therapy

• Review of drug abuse testing and assessment of compliance

• Review of psychosocial needs and plan to address unmet needs (if any)

• Documentation that substantiates necessity for a periodic visit

Covered Providers:

Care must be provided by one or a combination of the following providers and take place as part of a certified opioid treatment program as delineated in 42 CFR 8.11:

• Physicians (MD/DO)

• Clinical psychologists

• Licensed Clinical Social Workers

• Nurse practitioners

• Clinical Nurse Specialists

• Physician Assistants

• Other providers of mental health services licensed or otherwise authorized by the state in which they practice (e.g., licensed professional counselors, licensed clinical alcohol and drug counselors, licensed marriage and family therapists, licensed clinical alcohol and drug counselors, certified peer specialists)

Duration of treatment:

There is no limitation to the duration of treatment.

All coverage criteria must be clearly documented in the patient’s medical record and made available to the A/B MAC upon request.

Summary of evidence (opening)

OUD is described by the CDC as a problematic pattern of opioid use that causes significant impairment or distress. The United States has experienced a sharp increase in the incidence of opiate use disorder over the last 3 decades. In 2020, 91,799 drug overdose deaths occurred in the US and an estimated 2.7 million people ages 12 or older reported having an OUD. 1 This corresponds with increased use of both prescription and illicit opioids. The number of overdose deaths due to opioids, including prescription opioids, heroin, and synthetic opioids was 10 times higher in 2021 than in 1999. 2

The effect of opioid agonists on mortality:

Santo et al performed a systematic review and meta-analysis of 15 randomized controlled trials (RCT) and 36 primary cohort studies. 3 The study found that the risk of all-cause, overdose, suicide, alcohol-related, cancer, and cardiovascular-related mortality was significantly lower for people with opioid dependence during opioid agonist treatment (OAT). The rate of all-cause mortality during OAT was more than half of the rate seen during time out of OAT. The findings were not significantly different when comparing methadone vs buprenorphine. Notably, the all-cause mortality was 6 times higher in the 4 weeks after OAT cessation.

Krawczyk et al studied a total of 48,274 adults admitted to outpatient specialty treatment programs in 2015-16 for primary diagnosis of opioid use disorder in Maryland. 4 The study population experienced 371 opioid overdose deaths. Periods in medication treatment were associated with substantially reduced hazard of opioid overdose death compared with periods in non-medication treatment. Periods after discharge from non-medication treatment and medication treatment had similar and substantially elevated risks compared with periods in non-medication treatments. Methadone and buprenorphine were associated with significantly lower overdose death compared with non-medication treatments during care but not after treatment is discontinued.

the full summary and analysis of evidence are in the CMS record.

Dates, lineage and related policies

Original determination effective
2024-10-20
Current revision effective
2024-10-20
Last reviewed by the contractor
2024-07-30
MCD version
3

Other related documents: A59885 (Response to Comments).

Using this policy on a claim

Match the documented indication to the covered indications above before the service is scheduled, carry a diagnosis from the article's covered list on the claim line, and keep the elements the documentation section asks for in the record, because the contractor can request it later through medical review. A denial under this policy arrives as CARC 50 with remark N115; the LCD lookup guide walks through the appeal path and the Advance Beneficiary Notice rules, and the Palmetto GBA hub lists every other active policy from the same contractor.

Frequently asked questions

What does LCD L39849 cover?

OTP treatment is considered reasonable and necessary for beneficiaries meeting all of the following requirements: The full indications and limitations are reproduced on this page from the CMS Medicare Coverage Database export of September 24, 2026.

Which states does LCD L39849 apply to?

Palmetto GBA applies it to Medicare claims in AL, GA, NC, SC, TN, VA, WV. A Local Coverage Determination binds only the contractor that wrote it; the same service in another jurisdiction is judged under that contractor's own policy or, where none exists, claim by claim.

Which diagnosis codes support medical necessity under LCD L39849?

The companion billing and coding article A59718 lists 39 ICD-10-CM codes in 1 group that support medical necessity and 299 that do not; the first 24 appear on this page and the complete list is in the article on cms.gov.

How do I appeal a denial under LCD L39849?

The remittance carries claim adjustment reason code 50 with remark code N115, naming the LCD. Compare the documented indication with the policy's covered indications and the article's diagnosis list, then file a redetermination within 120 days with the record attached; if the service genuinely falls outside the policy, the patient can be billed only when a valid Advance Beneficiary Notice was obtained before the service.

Sources

Every figure on this page is taken from the CMS publications below, as released by the Centers for Medicare & Medicaid Services. Projection built 2026-10-02. Verify against the primary file before billing or contracting decisions.

Disclaimer

The policy text and code lists are reproduced from the CMS Medicare Coverage Database export as an operational reference. Verify against the current LCD and article on cms.gov before billing; coverage depends on the full record and the contractor. Not legal, clinical or billing advice.